Privacy Policy, Clex Keyboard for iOS (archived 2026-08-18 version)

Archived version. This is the privacy policy for Clex Keyboard for iOS that applied from 18 August 2026 until 20 August 2026. It is kept for reference and is no longer in force. The current policy is at clex.ai/en/legal/privacy-policy-ios/.

Effective date: 18 August 2026

This policy covers Clex Keyboard for iOS. The other Clex products, and the Clex website, are covered by the general Clex privacy policy. Where the two describe iOS behaviour differently, this one is the accurate document.

At a Glance

1. Who We Are

This Privacy Policy is issued by Clex A/S, a Danish corporation (CVR 37750840) with registered address at Ewaldsgade 9, 1., 2200 Copenhagen N, Denmark. For the Swedish market, Clex Sweden AB (org.nr 559544-8001) is the contracting party.

Clex develops language-technology writing support for the care sector. This policy describes how we handle information when you use Clex Keyboard for iOS.

Clex A/S is the data controller for the data described in section 4. The organisation that deployed Clex to you (municipality, care provider, or employer) remains the controller for the records its staff write in its own systems. We never receive those records.

2. Scope

This policy covers Clex Keyboard for iOS, distributed through the App Store and through managed device deployment. The other Clex products, and the Clex website, are covered by the general Clex privacy policy on clex.ai. Where the two documents describe iOS behaviour differently, this one is the accurate document.

The app is designed for professional care workers who document care activities within their organization’s electronic health record (EHR/EOJ) systems.

3. Our Approach to Privacy

Clex Keyboard is built on a local-first, privacy-by-design architecture:

• The free text you write stays on your device. It is not sent to us, and we cannot read it.
• Word prediction, sentence suggestions, sentence correction, translation, speech to text, and read-aloud all run on the device, using language models stored in the app.
• What does leave the device is a licence check, a set of usage measurements, and requests for model files. Section 4 lists every field.
• No keystrokes are logged, monitored, or transmitted at any point.

The usage measurements are daily counts of feature use. They carry no identifier for you or your device. Sections 4.2 and 4.3 describe the whole report and what becomes of it.

About the keyboard access warning. When you enable Clex Keyboard and grant it full access, iOS displays a standard warning that the keyboard developer may be able to transmit what you type. This warning is shown for all third-party keyboards and is not specific to Clex. Clex Keyboard does not collect, store or transmit the text you type. Section 4 lists everything the app does send, and section 5 lists what it never sends.

Clex is made for care workers, and in particular for those who are dyslexic or who find reading and writing difficult. The fact that someone uses a writing aid can say something personal about them. Under the GDPR that kind of information is protected by Article 9, and we treat the usage measurements that way: they are counted per organisation, never per person. We do not ask whether you have a reading difficulty, we do not record a diagnosis, and we do not infer one.

4. What Data Is Processed

4.1 What Leaves Your Device

Nothing else is transmitted. There is no request that carries the text you write.

4.2 The Usage Measurements: What Is in a Report

One report describes one calendar day. This is the whole report, and nothing else:

• the date it describes, as a day only, with no clock times
• the app version, shortened to its first two numbers
• the keyboard language, if it is Danish, Swedish, English or German. Every other language is reported as “none”
• three fixed labels, identical in every report from every device: the name of the report format, the product (“keyboard iOS”) and the platform (“iOS”)
• a random report number, created for that one report, used only so a repeated upload of the same report is not counted twice
• the counters: for each measured thing, the number of times it happened that day

If the keyboard language or the app version changes during a day, the day’s counts are split into one report per combination, each still describing only that calendar day.

The counters record how many times a feature was used or failed that day: a suggested word taken, a sentence correction started or accepted, a translation produced, text read aloud, a dictation started, finished, or cancelled, the language or a setting changed, and whether the keyboard was used at all that day. Response times are reported as counts within fixed ranges, never as individual measurements.

A report never contains what you typed, which app you were typing in, any time of day, any character count, or any identifier for you or your device. It is sent with your organisation’s access token, section 4.4, so we can tell which organisation it belongs to, and no more.

4.3 What Happens to a Report After It Arrives

A report is checked, then added, then gone. Our service accepts only the field names listed in 4.2 and only counter names from a fixed list. Anything else is refused. The accepted numbers are added into a running daily total for your organisation, and the report is not written to a file or a table anywhere. There is no record from which a single day’s upload could be pulled back out.

What is stored is a total, not an event. One stored row is: the date, the organisation, the product, the platform, the app-version bucket, the language, the counter name, and the number. There is no row for a device, an installation, a session, or a person, because no such value ever reaches the service.

The report number is used once and expires. The random number in 4.2 is kept on its own for a short period so that the same report cannot be counted twice, then it is deleted automatically. It identifies a report, never an app or a user.

We do not record where the report came from. The service does not read or store the IP address a report arrives from, and it does not store browser or device signatures.

Only totals can be read back, and only internally. The interface that reads this data requires an internal credential. The credential the app uses to upload cannot read anything. When totals are read back, the language and app-version breakdowns are deliberately dropped, so that a small group cannot be isolated within an organisation.

It deletes itself. Totals are deleted automatically 24 months after the day they describe. If a customer relationship ends, we can erase every total belonging to that organisation on request.

4.4 The Access Token

The token identifies the licensed organisation, its expiry, and a label your organisation configured. The token carries no name or contact detail for you, it is never stored on our side, and it is not written to our logs.

4.5 Model and Language Downloads

Requests for model files carry no identifier at all: no account, no licence, no device ID. As with any download, the server that delivers the file can see your IP address. Downloads happen on first use of a language or feature and when models are updated.

4.6 Local Features (No User Text Transmitted)

These features run on your device. No user text is sent to Clex or to any third party for them:

• Word prediction.
• Sentence suggestions and sentence correction, produced by language models stored in the app.
• Translation. Language files are downloaded once on first use and then kept on the device.
• Read-aloud and text-to-speech, using offline voices on your device.
• Speech to text, described in section 6.

No user text is included in any download or network request related to these features.

5. What We Do Not Collect

We do not collect or store:

• The text you type or dictate into EHR/EOJ systems or any other application
• The name of the app you are typing in
• The length of what you write. No character counts leave the device
• The time of day you type. A usage report names only the calendar day it describes
• Keystrokes, keystroke timing, or input patterns
• Personal data such as names, addresses, phone numbers, or health records of any individual
• The audio you speak to the app
• Photographs or other user-generated media
• Information from the EHR/EOJ systems where text is entered
• Device contacts, location, call logs, SMS, or browsing history
• Any identifier for you, your device, or your installation

The app contains no third-party analytics, crash-reporting, advertising or attribution components. Usage measurements go only to Clex’s own servers.

6. Speech to Text and the Microphone

Speech to text writes down what you say. It is optional. The Clex app asks for microphone permission the first time you use it, and the keyboard works fully if you decline.

iOS does not allow a keyboard itself to use the microphone, so the recording runs in the Clex app: the first time you press the microphone key, and again whenever iOS has closed the Clex app in the background, the keyboard opens the Clex app, which asks for the microphone permission and switches dictation on. Dictation then stays on until you switch it off in the app, which you can do at any time, or until iOS closes the app; it does not switch itself off after a while.

• While dictation is switched on, your device shows the microphone indicator, because the app holds the microphone open so that a recording can start the moment you press the microphone key. Sound that arrives while you are not recording is discarded as it arrives. It is not kept, not interpreted, and not sent anywhere.
• A recording starts when you press the microphone key and stops when you press it again. It also stops on its own after a pause in speech, and after 30 seconds at most.
• Audio is transcribed by a model stored on the device. It is held in memory while it is transcribed. It is not written to a file, not kept after the transcription, and not uploaded. It is not sent to Apple’s dictation service either.
• The transcription is inserted into the text field you are writing in, the same way as if you had typed it. The app keeps no copy of it.
• Speech to text is available for Danish and Swedish.

The permissions this involves:

7. Legal Basis (GDPR Article 6)

Since the free text stays on the device and we receive no records about the people your organisation documents, a data processing agreement between the organisation and Clex is generally not required for that content. What we do process is our own organisation-level usage totals, which carry no identifier for any person, and for which Clex is the controller. If your organisation concludes that supplementary documentation is needed, we can support that assessment.

We carry out no automated decision-making or profiling within the meaning of Article 22. The app proposes draft sentences and corrections, and the care worker decides whether to use each one. No automated decisions are made about individuals and no profiles are built.

8. Your Rights Under the GDPR

You have the right to access the data we hold about you, to have it rectified, erased, or its processing restricted, to object to processing based on our legitimate interest, and to receive it in a portable form.

Write to Email us. We answer within one month, as Article 12 requires. Be aware of what the answer will be: because a usage total holds no identifier for any person, we have no way to search it for you, and no way to separate your share of it from your colleagues’. That is a consequence of the design in section 4.3, not a refusal. An objection to the usage measurements is handled at organisation level, where the data exists: your organisation can have every total belonging to it erased, as described below.

You can also do these things yourself, at any time, without asking us:

• Delete everything held locally, by removing the app from your device.
• Disable the keyboard, in Settings, which stops the keyboard from processing anything further.
• Switch off dictation, in the Clex app, which releases the microphone immediately, section 6.
• Decline the microphone permission, or withdraw it in iOS Settings. Speech to text is optional and the keyboard works without it.

Your organisation can ask us to erase every usage total belonging to it, and we do that on request.

You may lodge a complaint with your supervisory authority:

9. Data Sharing and Sub-processors

We do not sell, rent, or trade personal data. These providers are involved in delivering the service:

No other third-party service receives data from the app in normal operation. The on-device components process data locally and transmit nothing.

10. Infrastructure and Data Residency

All Clex-managed processing of the data in section 4 takes place on servers in the European Union, hosted in Germany.

• Licence validation and usage measurements are received by our servers in Germany.
• Model files are delivered from European edge locations only, and visitor IP addresses are anonymised at the edge before any access log is written.
• The architecture is designed to keep external service dependencies few and to keep server-side operations inside the EU.

The full sub-processor register is available on request.

11. Data Security

Traffic between the app and Clex-managed servers is encrypted in transit. The access token travels only as a credential for that connection and is not stored or logged on our side. Data held on your device stays inside the app’s storage area, protected by iOS’s security model. Server infrastructure is protected using industry-standard security controls.

We apply commercially reasonable security measures. No method of electronic transmission or storage is completely secure, so we design the systems to keep the amount of exposed data small in the first place.

12. Data Retention

• On your device: until you remove the app, which removes everything it has stored. A usage report not yet sent is kept for at most 14 days, then deleted instead of sent.
• Usage totals on our servers: deleted automatically 24 months after the day they describe, and sooner if your organisation asks or its contract ends. Individual reports are never retained at all, as section 4.3 describes.
• Licence validation records: kept for the duration of the customer contract.
• Free text from app usage: never held on Clex servers, because it is never sent there.

13. Children’s Privacy

Clex Keyboard is made for professional care workers in an organisational context, including students in care-sector vocational programmes. It is not directed at children, and we do not knowingly collect information from anyone under the age of 16.

14. Changes to This Policy

We update this policy as the app changes. When we do, we change the effective date at the top and post the revised version on our website. Material changes are described rather than made silently. Superseded versions remain available: the version effective 11 August 2026 is archived here.

15. Contact